Jonathan O’Neill OBE
is the Managing Director of the Fire Protection Association (FPA)
Moving competency forward post-Grenfell
In the aftermath of the Grenfell tragedy, an Independent Review into Building Regulation and Fire Safety was commissioned by the UK Government. Led by Dame Judith Hackitt, the review urged a “radical rethink of the whole system and how it works”, claiming that the industry “has not reflected and learned for itself, nor looked to other sectors”. So, has it been successful?
The Hackitt Review was a significant piece of work that recommended a more robust approach to managing higher-risk residential buildings (HRRBs). The review has put greater pressure on the construction industry and pushed for individuals – including architects and building designers – to increase their understanding of fire risks, as well as the importance of using the appropriate materials and systems to maximise safety.
But what specific implications does the review have for building design and construction? It found that the current regulatory system does not properly identify who the key duty holders in the procuring, design and construction of buildings should be and the key accountabilities that flow from these roles. It then goes on to make specific recommendations, including highlighting the roles of principal designers and specialists commissioned to support and the need for them to have robust and accountable systems; recommendations that are aligned closely with those described in the Construction Design and Management Regulations 2015.
The review identified that all those involved in supporting the principal designer should also have the suitable and certified skills, knowledge and experience (i.e. competency) to perform those roles. The issue of fire safety competence is fundamental to improving standards, yet across the board – including within roles in building design, construction and building and facilities management – tasks are often performed without the necessary skills and experience. We only need to look to the Grenfell and earlier Lakanal House fires as evidence for this.
It is recognised that architectural design courses devote only a minor proportion of time to the consideration of fire safety requirements. However, it is vital that architects and designers recognise the limitations of their competence and consult or appoint competent accredited professionals with demonstrable specialist expertise when necessary. For example, while it is understandable that an architect may not have in-depth knowledge of certain fire safety requirements in relation to building design, particularly for complex, multi-occupancy new builds or refurbishment projects, they should engage a competent fire consultant or, where necessary, fire engineer to ensure that fire safety is prioritised within their designs. They must similarly ensure that they engage with competent specifiers to ensure that product and material choices will meet the design criteria for fire safety performance.
Accountability cannot simply be passed down the supply chain as we have seen occur historically. The Hackitt Review’s identification of the need for ‘duty holders’ is a welcome first step in clearly identifying roles and responsibilities, but we have to see this carried through in practice, and we must ensure these individuals – including building designers – have the right skills and competencies themselves.
Following the Hackitt Review, the Competence Steering Group (CSG) – a cross-industry body backed by the Government, Industry Safety Steering Group (ISSG), Dame Judith Hackitt herself and representing over 150 organisations – also released its report, ‘Setting the Bar: a new competence regime for building a safer future’, in October 2020. This provided a blueprint for improving competency and outlines the requirements of duty holders in the building design and management process. The CSG’s report is welcomed; however, the size of the task at hand is significant. An ISSG report from 2020 identified a “lack of widespread, proactive” leadership on building safety.
What does competency mean?
While events such as Grenfell have shone a light on the varying levels of competency within the industry, there is currently still no consistent definition of what competency means, which makes holding people accountable much more difficult. Both the Hackitt Review findings and the subsequent Setting the Bar report have suggested that the idea of competence must be relevant to the individual situation. However, this does not take away from the fact that individuals must have sufficient training, experience or knowledge to allow them to act within best practice. It is the FPA’s view that best practice should, of course, be determined with thorough reference to current guidelines, but that in many cases, these don’t go far enough. For example, while Building Regulations enforce stricter fire safety requirements for buildings over 18m tall, these are general guidelines and don’t take into account the specific requirements of the building or the occupants within it. Nor for that matter do they consider the stated requirements of the client, which may look beyond the basic legislative requirements for life safety to include aspects that will ensure a building’s resilience to fire. Individual design features have their own specific impact upon fire safety, and it is, therefore, vital that these factors are properly assessed by a competent individual, with recommendations acted upon – even if they are to the detriment of planned design features or material choices.
A truly competent architect or construction professional should not make decisions based solely on the height of the building. They must consider, amongst many other things, the fundamental issues of occupancy type, occupant profile, the evacuation procedure and how the building will be used. We must see Building Regulations and associated prescriptive guidance published in the Approved Documents as the bare minimum and seek to go above and beyond this to protect lives and property alike.
It is critical for all those involved in the design, construction and management of a building to remember that they play a vital role in the future of its safety and the welfare of its inhabitants. Therefore, constructors and architects should be taking all necessary steps to ensure they are operating in alignment with fire safety best practice and seeking the appropriate, competent external support in order for them to do so.